Epstein Secrets

e 9:08-cv-80736-KAM Document 100 Entered on FLSD Docket 09/27/2011 Page 2 of 12 has been waived. The United States further agrees that, in light of the Supreme Court's guidance on the Sixth Amendment Right to Counsel, the protections provided to civil mediation proceedings should extend to confidential plea negoti

5-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 371-06421 Fax (305) 358-2006 E-mail: [email protected]

e 9:08-cv-80736-KAM Document 100 Entered on FLSD Docket 09/27/2011 Page 2 of 12 has been waived. The United States further agrees that, in light of the Supreme Court's guidance on the Sixth Amendment Right to Counsel, the protections provided to civil mediation proceedings should extend to confidential plea negoti

5-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, FL 33131 (305) 371-06421 Fax (305) 358-2006 E-mail: [email protected]

ms. The victims made two principal arguments for dismissal: first, that this Court lacks jurisdiction over such an interlocutory appeal in light of the Supreme Court's recent decision in Mohawk Industries, Inc.'. Carpenter, 130 S. Ct. 599 (2009) (attorney-client privilege ruling not immediately appealable; any inj

The foregoing document was served on July 16, 2013, on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. Martin G Weinberg, P.C. /s/ Paul G. Cassell Paul G. Cassell 1 EFTA00209506

iminal prosecutors seeking to force him to plead guilty to criminal charge. Moreover, the cases Epstein relies upon are older cases, decided before the Supreme Court's recent decision in Mohawk. The Mohawk decision makes clear that even as to highly sensitive attorney-client materials, "[a]ppellate courts can reme

The foregoing document was served on July 12, 2013, on the following using the Court's CM/ECF system: Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. ,ill e• A et• 11 1 1 M ( ( Martin G. Weinberg Martin G. Weinberg, PC Paul G. Cassell EFTA00209529

S COURT LACKS JURISDICTION TO ENTERTAIN EPSTEIN'S INTERLOCUTORY APPEAL OF THE DISTRICT COURT'S DISCOVERY ORDER DIRECTED TO THE GOVERNMENT. 10 A. The Supreme Court's Recent Decision in Mohawk Makes Clear that Privilege Rulings During Discovery are Not Immediately Appealable But Instead Must be Challenged (If Nec

rved on July 2, 2013, on the following using the Court's CMJECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. /s/ Paul G. Cassell Paul G. Cassell 22 EFTA00209594

picuously chosen to ignore recent controlling caselaw from the Supreme Court, which makes clear that an interlocutory appeal is not permitted. A. The Supreme Court's Recent Decision in Mohawk That Attorney-Client Privilege Rulings are Not Immediately Appealable Limits the Perlman Doctrine to Non-Litigants in a C

ved on June 28, 2013, on the following using the Court's CM/ECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. 16 EFTA00209615

ee - over the most important consideration, the strong public and private interests at stake. The Goodyear Tire analysis is far more consonant with the Supreme Court's teaching in Jaffee than is MTSG. In Baker v. Secretary, U.S. Dept of Transportation, 452 Fed. Appx. 934, 937 (11th Cir. 2012), this Court appeared

SOUTHERN DISTRICT OF FLORIDA BRIEF OF INTERVENORS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Tel: (305) 371-6421 Fax: (305)358-2006 [email protected] jp

t has made it abundantly plain that, whatever the outcome of this litigation, the agreement it made with Mr. Epstein will stand. indeed, controlling Supreme Court case law prevents it from doing otherwise. Mr. Epstein has fully performed his side of the bargain with the government, and when a bargain is based

te@usdoj goy LEAD ATTORNEY ATTORNEY TO BE NOTICED EFTA00177831 Case: 9:08-cv-80736-KAM As of: 06/26/2013 07:08 PM EDT 2 of 16 Roy Black Black, Srebnick, Komspan &Stumpf, P.A. 201 South Biscayne Boulevard Suite1300 Miami, FL 33131 305-371-6421 intervenor Martin G. Weinberg J ntervenor Jay Lef

authority to review a grand jury subpoena for reasonableness. See, e.g., United States v. R. Enterprises, Inc., 498 U.S. 292, 300-01 (1991). While the Supreme •Court has held that grand jury subpoenas are presumed reasonable, that presumption may be overcome and a subpoena quashed where, as here, "there is no re

e held that "when the government seeks to seize the information stored on a computer, as opposed to the computer itself, that underlying 28 Black, Srebnick. Komspan & Stumpf 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305-371-6421 • Fax 305-358-2006 • www.RoyBlack.com EFTA0171